1.1. This privacy policy (“Policy”) relates to the website Insight and any subdomain or any such related website and/or mobile application for such website (together with the “Website”).
1.2. You should read this Policy carefully as it contains important information about how we will use your Information (as defined below in clause 4.1). In certain circumstances (see below) you will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit such Information to or through the Website. For further information about consent see clause 7 below.
1.3. We may update this Policy from time to time in accordance with clause 17 below. This Policy was last updated on 09th March 2021.
1.4 If you have been referred to Innovate by your Local Authority (Council) and we are providing you with support through the website/app the information you provide will be shared with your Local Authority as part of your care plan/support package/ and in managing the contract.
2.1. The terms “Insight” or “us” or “we” refer to Innovate Trust Ltd, the owner of the Website. We are a company registered in England and Wales under company number 02493904 whose registered office is at Innovate Trust, 433 Cowbridge Road East, Canton, Cardiff, CF5 1JH. The term “you” refers to the individual accessing and/or submitting Information to the Website.
2.2. We, as the Data Controller, can be contacted via our representative via email info@innovate-trust.org.uk or phone on 02920 382151.
3.1. References in this Policy to:
3.2. For the purposes of applicable Privacy and Data Protection Requirements, we (Innovate Trust) are a Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Privacy and Data Protection Requirements. “Personal Data” has a legal definition but, in brief, it refers to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Such information must be protected in accordance with applicable Privacy and Data Protection Requirements.
4.1. When you use the Website and/or when you otherwise deal with us we may collect the following information about you (“Information”):
4.2. We may monitor your use of the Website through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the Website. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. See clause 16 below for further information on our use of cookies.
4.3. Occasionally we may receive information about you from other sources, for example, our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, or search information providers you connect with through the Website, by your Local Authority (Council) as part of your care plan/support package or from any third-party websites and applications that integrate or communicate with the Website in relation to you. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
5.1. Subject to clause 5.2, we will keep your Data only for the purposes set out in the table below for:
5.2. If required, we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
6.1. From 25 May 2018, under applicable Privacy and Data Protection Requirements, we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is set out in the list below.
Why we will process your Information
The legal basis for which is…
7.1. As noted above, you will be required to give consent to certain processing activities before we can process your Information as set out in this Policy. Where applicable, we will seek this consent from you when you first submit Information to or through the Website.
7.2. If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account on the Website or by notifying us in writing.
7.3. If you withdraw your consent, and if we do not have another legal basis for processing your information (see clause 6 above), then we will stop processing your Information. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights (for which see clause 14 below).
7.4. Please note that if we need to process your information to operate the Website and/or provide our services, and you object or do not consent to us processing your Information, the Website and/or those services may not be available to you.
7.5 If you have been referred by your Local Authority (Council) and we are providing you with support through the website/app the information you provide will be shared with your Local Authority as part of your care plan/support package/ and in managing the contract. If you have been referred to us from your Local Authority Social Services, your consent is not needed to share your information.
8.1. You have the right at any time to ask us to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to info@innovate-trust.org.uk, or by using the tools available via the platform. Alternatively, you can follow the unsubscribe instructions in emails you receive from us and under your profile settings.
9.1. We may disclose your Information (including Personal Data):
9.2 We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Website. In such circumstances, we do not disclose any information which can identify you personally.
10.1. We will use technical and organisational measures in accordance with good industry practice to safeguard your Information, including the use of passwords, multi-factor authentication (wherever possible), antivirus and antimalware software, and data encryption.
10.2. While we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
We may monitor and record communications with you (such as emails or conversations via the platform) for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed in clause 6 above.
12.1. From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (“EEA”). Non-EEA countries that we may need to transfer your Information to include:
12.2. Such countries may not have similar protections in place regarding the protection and use of your data as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with applicable Privacy and Data Protection Requirements to ensure adequate protections are in place to ensure the security of your Information.
12.3. By submitting your information to us in accordance with this Policy, you consent to these transfers for the purposes specified in this Policy.
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Information; receive on his/her/their behalf any data protection notices, and give consent to the transfer of his/her/their Information abroad (if applicable).
If you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details in clause 20 below) giving us enough information to identify you and respond to your request.
14.1. You have the right to request access to information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
14.2. You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information to deal with the change or correction.
14.3. You have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case, we will let you know.
14.4. You have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see clause 14.6 below).
14.5. You have the right to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different data controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you, we will let you know.
14.6. You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
14.7. We do not use automate processing for the purpose of profiling or decision making, but if we did, you would have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you, we would let you know.
14.8. You have the right to object to direct marketing, for which see clause 8.3 above.
15.1. We welcome your feedback and questions on this Policy. If you wish to contact us, please email us at info@innovate-trust.org.uk or call on 02920 382151.
15.2. If you have any concerns about how we collect or process your Information then you also have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.
16.1. Our software may issue ‘cookies’ (small text files) to your device when you access and use the Website and you will be asked to consent to this at the time (e.g. when you first visit our
website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
16.2. Our Website uses cookies and other tracking and monitoring software to: distinguish our users from one another; collect standard Internet log information; and to collect visitor behaviour information. The information is used to track user interactions with the Website and allows us to provide you with a good experience when you access the Website, helps us to improve our Website, and allows us to compile statistical reports on Website visitors and Website activity.
16.3. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however, please note that some of our Website features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.
17.1. We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on this page, and place notices on other pages of the Website as applicable, so that you may be aware of the Information we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version of this Policy as it will apply each time you access the Website.
17.2. This Policy was last updated on 09th March 2021.
18.1. Our Website may contain links to other websites. This Policy only applies to our Website. If you access links to other websites any Information you provide to them will be subject to the privacy policies of those other websites.
18.2. We have no control over third party websites or systems and accept no legal responsibility for any content, material or information contained in them. Your use of third party sites or systems will be governed by the terms and conditions of that third party. It is your responsibility to ensure you are happy with such third-party terms and conditions.
18.3. The display of any hyperlink and/or reference to any third-party website, system, product or service does not mean that we endorse that third party’s website, products or services and any reliance you place on such hyperlink, reference or advert is done at your own risk.
This Policy aims to provide you with all relevant details about how we process your information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
Our mobile application will request access to:
You have the right to decline and/or remove access to this via your settings at any time. We have this option available as we use webRTC to allow for video and audio communication via a third party, within our app for users.
If you wish to contact us, please email us at info@innovate-trust.org.uk or call on 02920 382151